AML & KYC Notice — Vaulta Pay

VaultaPay AML & KYC Notice

1. Introduction

This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Notice explains the identity verification, customer due diligence and ongoing compliance measures applied by VaultaPay Solutions FZC LLC.

This Notice forms part of the legal agreement governing your use of the VaultaPay platform and should be read together with the:

Terms & Conditions
Privacy Policy
Cookie Policy
Risk Disclosure
Complaints Policy

By using the Services, you acknowledge that VaultaPay may request information and documentation necessary to verify your identity, assess risk and comply with applicable legal and compliance obligations.

2. Our Commitment

VaultaPay is committed to maintaining a secure platform and supporting efforts to prevent:

money laundering;
terrorist financing;
fraud;
sanctions evasion;
identity theft;
corruption;
bribery;
financial crime.

To achieve this, all customers are subject to appropriate verification and ongoing monitoring.

3. Customer Due Diligence (CDD)

Before providing access to certain Services, VaultaPay will carry out Customer Due Diligence ("CDD").

The level of due diligence applied may vary depending on factors such as:

customer type;
products used;
transaction activity;
country of residence or incorporation;
ownership structure;
overall risk profile.

Customers may be required to complete verification before an account is activated or before specific services become available.

4. Identity Verification for Individuals

Individual customers may be required to provide:

full legal name;
date of birth;
residential address;
nationality;
government-issued photo identification;
proof of address;
contact information;
selfie or liveness verification where applicable.

VaultaPay may request additional information where necessary to complete verification or satisfy ongoing compliance requirements.

5. Business Verification (KYB)

Business customers are subject to Know Your Business ("KYB") procedures.

Information requested may include:

certificate of incorporation;
articles of association or equivalent constitutional documents;
registered office address;
trading address;
company registration number;
tax identification details;
description of business activities;
expected transaction volumes and jurisdictions;
ownership structure.

Additional documentation may be requested where required.

6. Ultimate Beneficial Ownership (UBO)

To understand who ultimately owns or controls a business customer, VaultaPay may require information relating to Ultimate Beneficial Owners ("UBOs").

This may include:

full name;
date of birth;
nationality;
residential address;
ownership percentage;
identification documents;
verification of control.

Business customers must notify VaultaPay promptly of any material changes to their ownership or control.

7. Source of Funds and Source of Wealth

Where appropriate, VaultaPay may request information demonstrating the origin of funds or wealth used in connection with the Services.

Supporting documentation may include:

payslips;
employment contracts;
bank statements;
audited financial statements;
sale agreements;
inheritance documentation;
investment sale proceeds;
tax returns;
invoices;
contracts.

The documentation requested will depend on the customer's circumstances and risk profile.

8. Sanctions Screening

VaultaPay may screen customers, authorised users, beneficial owners, counterparties and transactions against applicable sanctions lists.

Screening may occur:

during onboarding;
before transactions are processed;
periodically throughout the customer relationship.

Where screening identifies a potential match, additional information or documentation may be requested before services can continue.

9. Politically Exposed Persons (PEPs)

VaultaPay may identify whether a customer or beneficial owner is a Politically Exposed Person ("PEP"), a family member of a PEP or a close associate of a PEP.

PEP status does not automatically prevent access to the Services.

However, additional due diligence and ongoing monitoring may be required.

10. Ongoing Monitoring

Customer relationships are monitored throughout their lifecycle.

Monitoring may include:

transaction analysis;
account activity reviews;
behavioural monitoring;
sanctions screening;
periodic review of customer information;
requests for updated documentation.

Customers agree to provide updated information when reasonably requested.

11. Transaction Reviews

Certain transactions may be reviewed before processing.

Factors that may trigger a review include:

unusually large transactions;
significant changes in transaction patterns;
activity inconsistent with the customer's expected profile;
cross-border payments involving higher-risk jurisdictions;
unusual digital asset transfers.

Reviews are conducted to help protect customers and maintain the integrity of the platform.

12. Requests for Additional Information

VaultaPay may request additional information or documentation at any time.

Examples include:

invoices;
contracts;
proof of ownership;
proof of source of funds;
explanation of transaction purpose;
supporting commercial documentation.

Failure to respond within a reasonable timeframe may affect the availability of the Services.

13. Record Retention

VaultaPay retains identification and compliance records for the period required by applicable legal and regulatory obligations.

Records may include:

onboarding documentation;
identity verification records;
transaction history;
compliance reviews;
correspondence relating to customer due diligence.

Records are stored securely and protected in accordance with our Privacy Policy.

14. Customer Responsibilities

Customers are responsible for:

providing accurate information;
ensuring submitted documentation is current and authentic;
notifying VaultaPay of material changes to their circumstances;
responding promptly to reasonable compliance requests;
using the Services only for lawful purposes.

Providing false or misleading information may result in suspension or termination of Services.

15. Suspension or Restriction of Services

VaultaPay may suspend, restrict or terminate access to the Services where:

required information is not provided;
verification cannot be completed;
fraudulent or suspicious activity is identified;
continued provision of the Services would create legal, operational or compliance risk;
required by applicable law or a lawful request from a competent authority.

Where legally permitted, VaultaPay will seek to notify the customer of such action.

16. Contact Information

If you have questions regarding this AML & KYC Notice or require assistance with verification, please contact:

VaultaPay Solutions FZC LLC

Floor 26
Amber Gem Tower
Sheikh Khalifa Street
Ajman
United Arab Emirates

Email: support@vaulta-pay.com

17. Regulatory Information

VaultaPay operates through the financial infrastructure of Swiss Fiat AG.

Swiss Fiat AG is incorporated in Switzerland with its registered office at Alpenstrasse 1, 6004 Lucerne, Switzerland, and is registered under company number CHE-311.324.141.

Swiss Fiat AG is affiliated with SO-FIT – Organisme de Surveillance pour Intermédiaires Financiers & Trustees (Affiliation No. 1524) as a financial intermediary in accordance with the Swiss Anti-Money Laundering Act (AMLA). SO-FIT is a self-regulatory organisation recognised by the Swiss Financial Market Supervisory Authority (FINMA).